2025 Tariffs
OCEANAIR has compiled data from the Federal Register regarding tariffs enacted under the Trump Administration. Our goal is to maintain and update this information to better assist our clients in reviewing applicable tariffs based on their countries of origin and commodities. Where relevant, we provide links to detailed lists for further reference.
De Minimis: Each tariff-impacting Executive Order has aimed to limit de minimis treatment, subjecting entries valued under $800 to the same supplemental tariff programs as formal entries. Given the significant volume affected, the administration has suspended these changes until the Secretary of Commerce confirms that “adequate systems are in place to fully and expediently process and collect tariff revenue.”
(last updated 03/14/25)
Date Implemented | Program | HTS | Percent | Countr(ies) | Description | Exceptions | Links |
03/12/2025 | Section 232 | 9903.81.87 | 25% | ALL | Iron or steel products, including flat-rolled sheets, bars, rods, wire, sheet piling, rails, tubes, pipes, hollow profiles, ingots, and select stainless steel items (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.81.88 | 25% | ALL | FTZ-specific transactions completed before March 12. | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.81.89 | 25% | ALL | Derivative iron or steel products, including nails, tacks, staples, bumper stampings for motor vehicles, and body stampings for tractors (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.81.90 | 25% | ALL | Derivative iron or steel products, including fittings, wire, fencing, chains, springs, radiators, select tableware, kitchen and household articles, sinks, baths, horseshoes, and miscellaneous steel articles under tariff 7326.90.8688 when no specific HTS is provided (refer to the provided link for detailed classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.81.91 | 25% | ALL | Derivative iron or steel products, including select machinery parts, agricultural equipment components, certain furniture, and lighting parts (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.81.92 | 25% | ALL | HTS 9903.81.90 and 9903.81.91 apply to certain iron or steel products but provide exemptions when the melt and pour occur in the United States. | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.81.93 | 25% | ALL | FTZ-specific transactions conducted prior to March 12. | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.85.02 | 25% | ALL | Aluminum products, including unwrought aluminum, bars, rods, profiles, wire, plates, foil, tubes, pipes, tube and pipe fittings, castings, and forgings (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.85.04 | 25% | ALL | Derivative aluminum products, including stranded wire, cables with fittings or electrical conductors, motor vehicle bumper stampings, and body stampings for tractors (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.85.07 | 25% | ALL | Derivative aluminum products, including doors, certain cooking and kitchenware, and miscellaneous articles not covered under 7619.99.5190 (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.85.08 | 25% | ALL | Derivative aluminum products, including hinges, fittings, castors, parts of fans and heaters, parts of semiconductors, as well as certain furniture and sporting goods (refer to the provided link for specific HTS classifications). | There is no exclusion application process available at this time. | |
03/12/2025 | Section 232 | 9903.85.09 | 25% | ALL | HTS 9903.85.07 and 9903.85.08 apply to certain aluminum products, with exemptions if the aluminum is smelted and cast in the United States. | There is no exclusion application process available at this time. | |
03/04/2025 | IEEPA | 9903.01.24 | 20% | CN & HK | The order replaces the 2/5/25 IEEPA 10% with a 20% tariff, eliminating the previous 10% rate. | There is no exclusion application process available. 9903.01.21 covers donations of food, clothing, and medicine to relieve human suffering. 9903.01.22 applies to informational materials such as publications, posters, tapes, etc. 9903.01.23 pertains to goods that were exported before 2/1/25 and arrived before 3/7/25. | |
03/04/2025 — Suspended | IEEPA | 9903.01.10 (25%) / 9901.01.13 (energy, 10%) | 25% (10% energy and energy products) | CA | A 10% ad valorem duty is applied to all products with energy-related items, in addition to other duties and taxes. | Starting on 3/6, a 30-day pause is implemented for all USMCA-qualified goods, and the tariff on non-USMCA-qualified potash from Canada is reduced to 10%. 9903.01.11 covers donations of food, clothing, and medicine to relieve human suffering. 9903.01.12 applies to informational materials such as publications, posters, tapes, etc. 9903.01.13 pertains to energy and energy products at 10%. 9903.01.14 applies to USMCA-qualified goods from Canada. 9903.01.15 applies to potash from Canada that does not qualify for USMCA. | |
03/04/2025 — Suspended | IEEPA | 9903.01.01 | 25% | MX | An ad valorem duty is placed on all products, in addition to other duties and taxes. | Starting on 3/6, a 30-day pause is implemented for all USMCA-qualified goods, and the tariff on non-USMCA-qualified potash from Mexico is reduced to 10%. 9903.01.02 covers donations of food, clothing, and medicine to relieve human suffering. 9903.01.03 applies to informational materials such as publications, posters, tapes, etc. 9903.01.04 pertains to USMCA-qualified goods from Mexico. 9903.01.05 applies to potash from Mexico that does not qualify for USMCA. | |
02/05/2025 — Expiring 03/06/2025 | IEEPA | 9903.01.20 | 10% (Expiring) | CN & HK | A 10% ad valorem tariff is applied to all commodities, in addition to other duties and taxes. This tariff is set to expire on 3/6 and will increase to 20% thereafter. | There is no exclusion application process available. 9903.01.21 covers donations of food, clothing, and medicine to relieve human suffering. 9903.01.22 applies to informational materials such as publications, posters, tapes, etc. 9903.01.23 pertains to goods exported before 2/1/25 and arriving before 3/7/25. | |
Scheduled | |||||||
3/12/2025 | Section 232 | 25% | Multi | **Breakdown in March 11 Compliance Exclusive** | |||
4/2/2025 | Fair and Reciprocal Plan | TBD | Various | Response to tariffs on U.S. goods, taxes including VAT, and the rising costs of burdensome regulatory requirements and labor policies. |
Definitions:
IEEPA (International Emergency Economic Powers Act): Invoked citing national emergency due to drug activity, unfair trade practices, and immigration concerns (Mexico and Canada).
The Trade Expansion Act of 1962—Section 232: The importation of identified items presents a risk to national security, impacting the ability to maintain independence in steel, aluminum, and other critical commodities.
China Section 301 Tariffs Updates
In 2018, the U.S. imposed three rounds of tariffs on more than $250 billion worth of Chinese goods after its Section 301 investigation determined that China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation were unreasonable and discriminatory. The duties of up to 25% cover a wide range of products, from handbags to railway equipment.
On August 1, 2019, President Trump announced he will impose an additional 10% duty on the $300 billion, List 4 goods beginning September 1, 2019.
On August 13, 2019 the USTR delayed some of the additional tariffs on the proposed List 4 until December 15, 2019, List 4B, and removed some items from the list. However, many items will remain subject to the additional duties on September 1, List 4A.
Summary of Section 301 Tariffs
| List No. | Covered Products | Additional Tariff Rate | Effective Date |
| List 1 | $34 Billion
818 HTSUS Subheadings |
25% Increased to 30% |
July 6, 2018
October 15, 2019 (postponed from Oct. 1) |
| List 2 | $16 Billion
284 HTSUS Subheadings |
25% Increased to 30% |
August 23, 2018
October 15, 2019 (postponed from Oct. 1) |
| List 3 | $200 Billion
5,745 HTSUS Subheadings |
10% Increased to 25% Increased to 30% |
September 28, 2018
May 9, 2019 October 15, 2019 (postponed from Oct. 1) |
| List 4 | $300 Billion
3,805 HTSUS Subheadings |
10% | September 1, 2019 |
| List 4A | ~$120 Billion |
15% 7.5%
|
September 1, 2019
February 14, 2020 |
| List 4B | ~$180 Billion |
15% |
December 15, 2019 |
The USTR has made technical amendments to Lists 3, 4A, and 4B to relieve issues of double Section 301 tariffs on some goods. Effective September 24, 2019, the Section 301 additional tariff will not be imposed on goods classified under any of 39 subheadings “if the applied rate of duty for an entry is derived from another subheading and if the entry, for this reason, already is subject to the additional tariff.” In other words, if a component of a good in one of these subheadings is subject to the Section 301 tariff, the good itself will not be subject to that tariff as well.
